Proposed September 11, 2012 ATTACHMENT 4 Rule 74.20: 1

VENTURA COUNTY AIR POLLUTION CONTROL DISTRICT

RULE 74.20 - ADHESIVES AND SEALANTS

(Adopted 6/8/93, Revised 9/10/96, 1/14/97, 9/9/2003, 1/11/05, xx/xx/12)

A. Applicability

The provisions of this rule apply to any person who supplies, sells, offers for sale, 

manufactures, solicits the application of, or uses adhesives, sealants, sealant primers or 

adhesive primers in Ventura County. 

B. Requirements

1. Unless otherwise specified in Subsection B.2 or B.3, a person shall not apply any 

adhesives or any adhesive primers, which have an ROC content less water and exempt 

organic compounds in excess of 250 g/l (for low-solids adhesives or adhesive primers, 

the ROC content is based on a "grams per liter of material" basis).

2. Adhesives/Sealants/Adhesive Primers/Sealant Primers (Specific Applications): No 

person shall apply any adhesive, sealant or primer, which is defined under the following 

product categories, and has an ROC content, less water and exempt organic compounds 

in excess of the following limits, as applied (for low-solids adhesives, sealants or 

primers, the ROC content is based on a "grams per liter of material" basis).

Limits

"Grams of ROC per Liter of Adhesive, Sealant or Primer

Less Water and Exempt Organic Compounds"

Category

Architectural Adhesive Products:

Multipurpose Architectural Adhesive 70

Ceramic Wall Tile Adhesive 65

Cove Base Adhesive 50

Drywall Adhesive 50

Flooring Adhesives:

Ceramic Floor Tile 65

Outdoor Carpet 150

Indoor Carpet or Carpet Pad 50

Rubber Flooring 60

Subfloor Adhesive 50

VCT and Asphalt Tile 50

Wood Flooring 100

Other Flooring 150

Panel Adhesive 50
Proposed September 11, 2012 ATTACHMENT 4 Rule 74.20: 2

Limits

"Grams of ROC per Liter of Adhesive, Sealant or Primer

Less Water and Exempt Organic Compounds"

Category

Architectural Adhesive Products (cont.):

Roofing Adhesives:

Single Ply Roof Membrane 250

Nonmembrane Roof 300

Structural Glazing Adhesive 100

Structural Wood Member Adhesive 140

Miscellaneous Adhesives:

Contact Adhesive 80

Special Purpose Contact Adhesive 250

Sheet-Applied Rubber Lining Operations 850

Tire Retread 100

Traffic Marking Tape Adhesive 150

Top and Trim Adhesive 540

Plastic Welding Products:

ABS Welding 400

Cellulosic Plastic Welding

(except ethyl cellulose) 100

CPVC Welding 490

PVC Welding 510

Styrene-Acrylonitrile Welding 100

Plastic Welding Primer 650

Other plastic welding 500

Adhesive Primers:

Automotive Glass Adhesive Primer 700

Other Adhesive Primer 250

Sealants:

Architectural 250

Marine Deck 760

Nonmembrane Roof 300

Roadway 250

Single-Ply Roof Membrane 450

Other Sealants 420

Sealant Primers:

Architectural Nonporous 250

Architectural Porous 775

Marine Deck 760

Other Sealant Primers 750
Proposed September 11, 2012 ATTACHMENT 4 Rule 74.20: 3

3. Adhesives (Substrates or Nonspecific Operations): No person shall apply any adhesive 

to a substrate with an ROC content, "less water and exempt organic compounds" in 

excess of the following limits, as applied (for low-solid adhesives, sealants or primers, 

the ROC content is based on a "grams per liter of material basis").

If an adhesive is used to bond dissimilar substrates, the applicable substrate category 

with the highest ROC limit shall be the limit for that operation. If an operator uses an 

adhesive product listed in Subsection B.2, then the requirement in that section applies 

rather than this one.

Limits

"Grams of ROC per Liter of Adhesive

Less Water and Exempt Organic Compounds"

Substrate/Application

Fiberglass 80

Flexible Vinyl 250

Metal to Metal 30

Plastic Foam 50

Porous Material

 (Except Wood and Plastic Foam) 50

Wood 30

4. Substrate Surface Preparation:

Until December 1, 2012, Nno person shall use a material for substrate surface 

preparation that exceeds the following applicable limit:

Category Type of Limit Limit

Single Ply Roof ROC Composite 45 mm of Hg

 Membrane Installation Partial Pressure at 20oC

Inkjet Printer Head Assembly ROC Content 200 g/l of material

All Others ROC Content 70 g/l of material

Effective December 1, 2012, no person shall use a material for substrate surface 

preparation that exceeds the following applicable limit:

Category Type of Limit Limit

Inkjet Printer Head Assembly ROC Content 200 g/l of material

All Others ROC Content 25 g/l of material

5. Adhesive CleanupSolvent Cleaning:

Until December 1, 2012, Nno person shall use ROC-containing materials for the 

removal of adhesives or coatings from surfaces, other than spray application equipment, 

unless the ROC composite partial pressure of the materials used is less than 45 mm of 

Hg at 20 oC.

Comment [SC1]: This limit is unchanged based 

on operations at Ricoh.

Comment [SC2]: Consistent with definition in 

Rule 74.6
Proposed September 11, 2012 ATTACHMENT 4 Rule 74.20: 4

Effective December 1, 2012, No person shall use ROC-containing materials for solvent 

cleaning unless the ROC content is 25 grams per liter of material or lower.

6. Storage of ROC-Containing Materials: All ROC-containing materials, including but not 

limited to, adhesives, sealants, coatings, cleanup solvents or surface preparation 

materials, shall be stored in nonabsorbent, nonleakingclosed containers, which shall be 

closed except when adding or removing materials are nonabsorbent and do not leak. 

These storage containers shall be closed except when filling or emptying.

7. Adhesive Spray Application Equipment Cleaning: 

Until December 1, 2012, No person shall use ROC-containing materials for the cleaning 

of spray application equipment used in adhesive operations unless one of the following 

is used:

a. An enclosed gun washer or "low emission spray gun cleaner" that has been 

approved in writing by the APCO is properly used and is closed when not in use. 

The ROC composite partial pressure of organic solvents used shall be less than 

45 mm Hg at 20 oC; or

b. A solvent containing no more than 70 grams of ROC per liter of material shall 

be used for cleaning, flushing or soaking of filters, flushing lines, pipes, pumps, 

and other parts of the application equipment. Parts containing dried adhesive 

may be soaked in an organic solvent as long as the ROC composite partial 

pressure of the solvent is 9.5 mm Hg or less at 20 oC.

Effective December 1, 2012, No person shall use ROC-containing materials for the 

cleaning of spray application equipment used in adhesive operations unless a solvent 

containing no more than 25 grams of ROC per liter of material shall be used for 

cleaning, flushing or soaking of filters, flushing lines, pipes, pumps, and other parts of 

the application equipment.

8. Add-on Control Equipment Option: In lieu of complying with the provisions of 

Subsections B.1, B.2 or B.3, emissions of ROC may be controlled by an emission 

capture and control system, which reduces ROC emissions to the atmosphere, provided 

that:

a. The combined control and capture efficiency reduces emissions by at least 85 

percent, by weight, during any period of continuous operation not to exceed 24 

hours, and

b. Combustion temperature is continuously monitored when operating a thermal 

incinerator, and

c. Inlet and exhaust gas temperature is continuously monitored when operating a 

catalytic incinerator, and

Comment [SC3]: Consistent with Rule 74.12

Comment [SC4]: Moved the cleaning (stripping) 

requirement to Subsection B.9.

Comment [SC5]: Consistent with Rule 74.13. It 

is not necessary to specify the control device. No 

sources currently using control equipment.
Proposed September 11, 2012 ATTACHMENT 4 Rule 74.20: 5

d. Control device efficiency is continuously monitored when operating a carbon 

adsorber or control device other than a thermal or catalytic incinerator, and

e.b. Written approval for such equipment, in the form of an Authority to Construct 

and a Permit to Operate is received from the Air Pollution Control Officer 

(APCO).

9. Adhesive Strippers: No person shall use an adhesive stripper unless its ROC composite 

partial pressure is 9.5 mm Hg or less at 20 oC. 

10. Primers, Sealants or Adhesives Containing 1,1,1-Trichloroethane or Methylene 

Chloride: No person shall apply any primer, sealant or adhesive to any surface, if that 

product contains any 1,1,1-trichloroethane or methylene chloride. Adhesives containing 

methylene chloride used to plastic weld the following plastic substrates are exempt from 

this requirement:

a. Polycarbonate

b. Polysulfone

c. Acrylics including Polymethylmethacrylate (PMMA)

d. Phenylene-Oxide based resins

e. Polyetherimide

11. Prohibition of Specification: No person shall solicit, require for use, or specify the 

application of any adhesive, primer or sealant, if such use or application results in a 

violation of the provisions of this Rule. This prohibition shall apply to all written or 

oral contracts.

12. Compliance Statement Requirement: The manufacturer of any adhesive, sealant, sealant 

primer or adhesive primer subject to this rule and manufactured after July 14, 1997, 

shall include a designation of the maximum ROC or VOC content as supplied, 

including adhesive components, expressed in grams per liter or pounds per gallon 

excluding water and exempt organic compounds from the appropriate test method, on 

containers and data sheets. This designation shall include recommendations regarding 

thinning, reducing, or mixing with any other ROC or VOC-containing materials. This 

statement shall include the maximum ROC or VOC on an as-applied basis when used in 

accordance with the manufacturer's recommendations. 

13. Liquid Cleaning Material Compliance Statement: The manufacturer of liquid cleaning 

materials subject to this rule shall designate on product containers and data sheets the 

ROC content and ROC Composite Partial Pressure of cleaning materials as supplied. 

This designation shall include recommendations regarding mixing with any other ROC 

containing materials, and express the cleaning material ROC content when used in 

accordance with the manufacturer's recommendations. All letters and numbers used to 

designate ROC or VOC content on product labels shall be visible and legible.

14. Prohibition of Sales:
Proposed September 11, 2012 ATTACHMENT 4 Rule 74.20: 6

a. Except as provided in Subsections B.14.c, B.14.d, or B.14.e, no person shall 

supply, sell, or offer for sale any adhesive, sealant or primer which, at the time of

sale, is defined under a product category in Subsection B.2, and exceeds the 

ROC limits listed in Subsection B.2 after the specified effective dates. This 

provision only applies to products that are supplied to or sold to persons within 

the District.

b. Except as provided in Subsections B.14.c, B.14.d, or B.14.e, no person shall 

supply, sell, or offer for sale any adhesive, sealant, or primer which, at the time 

of sale, contains any 1,1,1-trichloroethane or methylene chloride, except for 

those adhesives designed to plastic weld polycarbonates, polysulfones, acrylics, 

phenylene oxide based resins or polyetherimides.

c. The sales prohibition in Subsections B.14.a and B.14.b shall not apply to any 

supplier or seller of any adhesive, sealant or primer as follows:

1) Any adhesive shipped outside of the District for use outside of the 

District.

2) The sale of adhesives to a user who has installed an APCD permitted 

ROC add-on control device. 

d. The sales prohibitions in Subsections B.14.a and B.14.b shall not apply to the 

sale of any adhesive, sealant, or primer, except plastic welding products, if:

1) The adhesive, sealant, or primer is sold in any container(s) having a 

capacity of 16 ounces or less (net volume) or 1 pound or less (net 

weight); and 

2) The total weight or volume of two or more containers packaged together 

must be less than 1 pound or 16 ounces, respectively, to qualify for this 

exemption.

e. The sales prohibitions in Subsections B.14.a and B.14.b shall not apply to any 

manufacturer of any adhesive, sealant, or primer if the manufacturer has 

provided an accurate compliance statement and if:

1) The product was not sold directly to a user or a sales outlet located in the 

District, or

2) The product was sold to an independent distributor that is not a 

subsidiary of, or under the direct control of the manufacturer.

C. Exemptions
Proposed September 11, 2012 ATTACHMENT 4 Rule 74.20: 7

1. This rule, except Section B.14, shall not apply to any stationary source that emits less 

than 200 pounds of ROC in every rolling period of 12 consecutive calendar months 

from adhesive and sealant operations. Emissions from cold cleaners, vapor degreasers, 

and aerosol products shall not be included in this determination. Any person claiming 

this exemption shall provide monthly records sufficient to substantiate this claim.

2. Exemption of Operations Subject to Other District Rules: The provisions of this rule 

shall not apply to the following operations that are subject to other District rules.

a. Assembling, manufacturing and repairing of aerospace components subject to 

Rule 74.13, excluding manufacturing of aircraft tires.

b. Any graphic arts operation subject to the requirements of Rule 74.19, Graphic 

Arts.

c. Any screen printing operation subject to the requirements of Rule 74.19.1, 

Screen Printing Operations.

3. Exemption of Specific Operations from ROC Standards for 

Adhesives/Sealants/Primers: The ROC limits of Subsections B.1, B.2, and B.3 of this 

rule shall not apply to the following operations.

a. Assembling and manufacturing of undersea-based weapon systems.

b. Testing and evaluation of adhesive or sealant products in any research and 

development or analytical laboratories.

c. Plastic welding operations used in the manufacturing of medical devices.

d. Tire repair operations, provided the label on the adhesive used states "For Tire 

Repair Only". 

e. Plaque laminating operations where adhesives are used to bond a clear, polyester 

acetate laminate to wood with lamination equipment installed prior to July 1, 

1992. 

f. Manufacturing operations of the following products: diving suits, rubber fuel 

bladders, inflatable boats, life preservers or other products designed for 

immersion in liquids. The adhesive products used by these operations must be 

labeled "For the bonding of immersible products only."

g. Inkjet printer head assembly operations where the ROC content of the adhesive 

used for laminating is less than 100 grams per liter of material.

h. Thin film laminating operations of magnetic or electronic components excluding 

inkjet printer head assembly operations.
Proposed September 11, 2012 ATTACHMENT 4 Rule 74.20: 8

i. Glass bonding and priming processes in automotive convertible top 

manufacturing operations.

4. Exemption of Specific Adhesives: 

a. Any adhesive, primer, or sealant that contains less than 20 grams of ROC per 

liter of material is exempt from all the provisions of this rule.

b. Any aerosol adhesive is exempt from all provisions of this rule.

c. Any cyanoacrylate or methyacrylate-based adhesive is exempt from all 

provisions of this rule.

5. The provisions of Subsection B.3 of this rule shall not apply to any person who uses less 

than 10 gallons per rolling period (consisting of 12 consecutive calendar months) per 

stationary source of an adhesive, a sealant, or primer in a separate formulation provided 

the total volume of noncomplying adhesives, sealants, or primers at a stationary source 

does not exceed 55 gallons per rolling period (consisting of 12 consecutive calendar 

months). If a specific adhesive, sealant, sealant primer or adhesive primer can be 

defined under one of the product categories in Subsection B.2, then this exemption does 

not apply. Any person seeking to claim this exemption shall notify the APCO in writing 

that a complying adhesive, sealant or primer is not available and maintain records 

sufficient to substantiate this claim.

6. Sell Through of Adhesives: A person may supply, sell, offer for sale, or apply a 

noncomplying adhesive for up to 6 months after the applicable effective date provided 

that:

a. Product complies with the ROC limit in effect at the time of manufacture.

b. Product was manufactured prior to the effective date.

c. Date of manufacture or a code indicating that date is clearly displayed on the 

product. If a manufacturer uses a date code to justify this sell-through 

exemption, the manufacture shall file an explanation of each code with the Air 

Pollution Control Officer.

D. Recordkeeping 

1. Any person subject to this rule shall:

a. Maintain a current filelist of eachall adhesives, sealants, primers, strippers and 

solvents in use and in storage that is required to be tracked by a District permit 

condition. The file shall provide all of the data that provides all information 

Comment [SC6]: Sell Through provision no 

longer needed.

Comment [SC7]: Consistent with Rule 74.12
Proposed September 11, 2012 ATTACHMENT 4 Rule 74.20: 9

necessary to evaluate compliance and shall includeing the following information,

as applicable:

1) A data sheet or material list giving material name and manufacturer 

identification.The name and manufacturer of each ROC-containing 

material including any catalysts, reducers, or other components used.

2) Any catalysts, reducers or other components used and the mMix ratio, if 

applicable.

3) The ROC content limit or ROC composite partial pressure limit from 

Section B, and the actual ROC content (less water and exempt organic 

compounds except low-solids coatings, which are expressed as grams per 

liter of material basis), as applied, or ROC composite partial pressure of 

the adhesive, sealant, primer, or solvent, or stripper.

4) Applicable ROC content limit or ROC composite partial pressure limit 

from Section B.

b. Maintain records of the monthly volume of each complying adhesive, sealant, 

primer or solvent, or stripper used that is required to be tracked by a District 

permit condition.

c. Maintain records of the daily volume of each noncompliant adhesive, sealant, 

primer or solvent or stripper used. Adhesives, sealants or primers qualifying for 

the exemption in Subsection C.5 shall not be subject to this daily recordkeeping 

requirement.

d. When compliance is achieved through the use of add-on control equipment, 

maintain records on a daily basis of key operating parameters for the emission 

control equipment, including, but not limited to:

1) Hours of operation

2) Routine and nonroutine maintenance

3) The applicable information specified in Subsection B.8

d. Any person using an emission control system as a means of complying with this 

rule shall maintain daily records of key system operating and maintenance 

procedures which will demonstrate continuous operation and compliance of the 

emission control device during periods of emission producing activities. 

2. All records shall be retained for at least two (2) years from the date of each entry and 

shall be available to District personnel upon request.

Formatted: Indent: Left: -0.5", Hanging: 2"

Formatted: Indent: Left: 0.5", Hanging: 1",

No bullets or numbering

Formatted: Indent: Left: -0.5", Hanging: 2"
Proposed September 11, 2012 ATTACHMENT 4 Rule 74.20: 10

E. Test Methods

1. The ROC and solids content of all adhesives products, sealants, primers and cleaning 

solvents, except as specified in Section E.3, shall be determined using EPA Reference 

Method 24 (40 CFR Part 60, Appendix A).

2. Exempt organic compounds shall be determined using ASTM D4457-91. For exempt 

compounds where no reference test method is available, a facility requesting the 

exemption shall provide appropriate test methods approved by the APCO and 

approvable by the U.S. EPA.

3. The ROC content of any plastic welding product shall be determined using Proposed 

SCAQMD Laboratory Method of Analysis for Enforcement Samples, Method 316a-92, 

“Determination of VOC in Material Used for Pipes and Fittings”(October 1996).

4. The capture and control efficiency of air pollution control equipment shall be 

determined according to EPA's technical document, "Guidelines for Determining 

Capture Efficiency," January 9, 1995, and Methods in 40 CFR 51 Appendix M, 

Methods 204-204F, as applicable: 

Methods 204, Criteria for and Verification of a Permanent or Temporary Total Enclosure 

Method 204A, VOC content in Liquid Input Stream

Method 204B, VOC Emissions in Captured Stream

Method 204C, VOC Emissions in Captured Stream (Dilution Technique)

Method 204D, VOC Emissions in Un-captured Stream from Temporary Total Enclosure

Method 204E, VOC Emissions in Un-captured Stream from Building Enclosure, and

Method 204F, VOC Content in Liquid Input Streams (Distillation Approach)

Control system efficiency shall be determined by 40 CFR 60, Appendix A, Method 18,

“Measurement of Gaseous Organic Compound Emissions by Gas Chromatography”,

Method 25, “Determination of Total Gaseous Nonmethane Organic Emissions as 

Carbon” or Method 25A, “Determination of Total Gaseous Organic Concentration 

Using a Flame Ionization Analyzer.”

5. ROC composite partial pressure shall be calculated using a widely accepted published 

source such as: Boublik, T., V. Fried and E. Hala, "The Vapor Pressure of Pure 

Substances," Elsevier Scientific Publishing Co. New York (1973); Perry's Chemical 

Engineer's Handbook, McGraw-Hill Book Company; CRC Handbook of Chemistry and 

Physics, Chemical Rubber Publishing Company (1986-87), and Lange's Handbook of 

Chemistry, John A. Dean, editor, McGraw-Hill Book Company (1985). The true vapor 

pressure of a component in a mix may be determined by ASTM Method D2879-96. The

ROC composite pressure of a solvent mix consisting entirely of ROC may be 

determined by ASTM Method D2879-8697, “Test Method for Vapor PressureTemperature Relationship and Initial Decomposition Temperature of Liquids by 

Isoteniscope.”.
Proposed September 11, 2012 ATTACHMENT 4 Rule 74.20: 11

6. Until December 1, 2012, Tthe active and passive solvent losses from spray gun cleaning 

systems shall be determined using SCAQMD's "General Test Method for Determining 

Solvent Losses from Spray Gun Cleaning Systems" dated October 3, 1989. The test 

solvent for this determination shall be any lacquer thinner with a minimum ROC 

composite partial pressure of 105 mm of Hg at 20 oC, and the minimum test 

temperature shall be 15 oC.

F. Violations

Failure to comply with any provision of this rule, including the requirement to maintain records 

or supply VOC or ROC information, or supply ROC composite partial pressure information, 

shall constitute a violation of this rule. Noncompliance determined by any test method 

specified or referenced in this Rule is a violation of this Rule. Where more than one approved 

test method may be applicable, sources shall not be required to demonstrate compliance using 

more than one approved test method.

G. Definitions

1. "ABS Welding Adhesive": Any adhesive that is intended by the manufacturer to weld 

acrylonitrile styrene (ABS) plastic. ABS is made by reacting monomers of acrylonitrile, 

butadiene, and styrene and is normally identified with ABS marking.

2. "Acrylic": Acrylic is any thermoplastic polymer or copolymer of acrylic acid, 

methacrylic acid, ester of these acids, or acrylonitrile. thatAcrylic contains at least one 

version of a methacrylate monomer, including but not limited to: methylmethacrylate or 

butylmethacrylate. 

3. "Adhesive": Any substance that is used to bond one surface to another surface by 

attachment.

4. "Adhesive Primer": Any coating that does not contain any adhesive and is intended by 

the manufacturer to be applied to a substrate, prior to the application of an adhesive, to 

provide a bonding surface.

5. "Adhesive Stripper": A volatile liquid applied to remove a cured or dried adhesive.

6. "Aerosol Adhesive": Any adhesive packaged as an aerosol product in which the spray 

mechanism is permanently housed in a nonrefillable can designed for hand-held 

application without the need for ancillary hoses or spray equipment. Aerosol adhesives 

include special purpose adhesives, mist spray adhesives, and web spray adhesives, as 

defined by the California Air Resources Board consumer product regulation found in 

Title 17 of the California Code of Regulations, beginning at Section 94507.

7. "Architectural Sealant Primer- Nonporous": Any sealant primer intended by the 

manufacturer to be applied to nonporous material surfaces on stationary structures, 
Proposed September 11, 2012 ATTACHMENT 4 Rule 74.20: 12

including mobile homes, and their appurtenances. Appurtenances include, but are not 

limited to: hand railings, cabinets, bathroom and kitchen fixtures, fences, rain gutters 

and downspouts, and windows.

8. "Architectural Sealant Primer- Porous": Any sealant primer intended by the 

manufacturer to be applied to porous material surfaces on stationary structures, 

including mobile homes, and their appurtenances. Appurtenances include, but are not 

limited to: hand railings, cabinets, bathroom and kitchen fixtures, fences, rain gutters 

and downspouts, and windows.

9. "Architectural Sealant": Any sealant intended by the manufacturer to be applied on 

stationary structures, including mobile homes, and their appurtenances. Appurtenances 

include, but are not limited to: hand railings, cabinets, bathroom and kitchen fixtures, 

fences, rain gutters and downspouts, and windows.

10. "Automotive Glass Adhesive Primer": Any adhesive primer that is intended by the 

manufacturer to be applied to automotive glass prior to installation with an 

adhesive/sealant. This primer improves adhesion to the pinch weld and blocks 

ultraviolet light.

11. “Capture Efficiency”: The percentage of ROC used, emitted, evolved, or generated by 

the operation, that is collected, and directed to an air pollution control device.

1112. "Carbon Adsorption": A carbon unit that is typically either a fixed-bed or a fluidizedbed design. ROC-laden air is pretreated, if necessary, to remove any solids, liquids, and 

long-chain, high-boiling organic compounds that might coat the carbon. The exhaust 

stream then passes through the adsorbing bed where the ROCs collect on the surface of 

the carbon.

1213. "Catalytic Incinerator": An incinerator that requires a catalyst to promote the oxidation 

of the ROCs at a lower temperature. The catalyst is often, but not always, a platinum 

serial metal deposited in a porous form onto a structure, such as a honeycomb, or 

pellets. The ROCs are preheated up to 650 to 900 oF and then enter the catalyst area. 

There the oxidation of the ROCs continues to produce an increase in temperature across 

the catalyst bed.

1314. "Cellulosic Plastics": Any plastic containing the naturally occurring polymer or 

polysaccharide, cellulose (C6H10O5)n. Examples includes cellulose acetate, cellulose 

acetate butyrate, cellulose nitrate and cellulose propionate.

1415. "Ceramic Tile Installation Adhesive": Any adhesive that is intended by the 

manufacturer to be used for installation of ceramic tiles.

1516. "Contact Adhesive": Any adhesive that is intended by the manufacturer to adhere to 

itself instantaneously upon contact and is indicated by the label or data sheet as a 

contact adhesive. This adhesive is applied to both adherents and allowed to become 
Proposed September 11, 2012 ATTACHMENT 4 Rule 74.20: 13

dry, which develops a bond when the adherents are brought together without sustained 

pressure. For the purpose of this rule, products that qualify as a contact adhesive using 

the above definition, and that are labeled exclusively for only one of the following 

applications shall not be required to meet the ROC limit for "Contact Adhesives" in 

Subsection B.2:

a. Single-ply roofing

b. Bonding of immersible products

c. Bonding of flexible vinyl to flexible vinyl

d. Nonmembrane roofing

1617. "Cove Base Installation Adhesive": Any adhesive that is intended by the manufacturer 

to be used for cove base (or wall base) installation. The cove base is generally made of 

vinyl or rubber, and is installed on a wall or vertical surface at floor level.

1718. "CPVC Welding": Any adhesive intended by the manufacturer for the welding of 

CPVC (chlorinated polyvinyl chloride) plastic. CPVC is a polymer of the monomer that 

contains 67 percent chlorine and is normally identified with a CPVC marking.

1819. "Cyanoacrylate Adhesive": Any adhesive that is a single-component reactive diluent 

adhesive that contains at least 85 percent by weight, methyl, ethyl, methoxymethyl or 

other functional groupings of cyanoacrylate.

1920. "Dry Wall Adhesive": An adhesive that is intended by the manufacturer to be used to 

install gypsum dry wall to studs or solid surfaces. 

2021. "Exempt Organic Compounds": As defined in Rule 2, Definitions, of these Rules.

2122. "Fiberglass": Fiberglass is any fiber reinforced plastic (FRP) surface that has fiber 

material set in a binding substance of plastic resins.

2223. "Flexible vinyl": Nonrigid polyvinyl chloride plastic with at least five percent, by 

weight, of plasticizer content. A plasticizer is a material, such as a high-boiling point 

organic solvent, that is incorporated into an adhesive to increase its flexibility, 

workability, or distensibility, and may be determined using ASTM Method E260-91 or 

from product formulation data.

2324. "Grams of ROC per liter of Adhesive, Sealant or Primer, less water and exempt organic 

compounds": The weight of ROC per combined volume of ROC and coating solids 

calculated using the following equation:

Grams of ROC per Liter of Adhesive Ws - Ww - Wes

 Less Water and Exempt Organic Compound = 

 Vm - Vw - Ves

Where: Ws = Weight of volatile compounds (grams)
Proposed September 11, 2012 ATTACHMENT 4 Rule 74.20: 14

Ww = Weight of water (grams)

Wes = Weight of exempt organic compounds (grams)

Vm = Volume of material (liters)

Vw = Volume of water (liters)

Ves = Volume of exempt organic compounds (liters)

2425. "Grams of ROC per Liter of Material": The weight of ROC per volume of material 

shall be calculated using the following equation:

Grams of ROC per Liter of Material Ws - Ww - Wes

= 

 Vm 

Where: Ws = Weight of volatile compounds (grams)

Ww = Weight of water (grams)

Wes = Weight of exempt organic compounds (grams)

Vm = Volume of material (liters)

2526. "Gun Washer": Electrically or pneumatically operated system that is designed to clean 

spray application equipment and minimize emissions. A gun washer may also be 

considered a gun cleaning system that consists of spraying solvent into an enclosed 

container using a snug fitting.

2627. "Inkjet Printer Head Assembly Operation": Any operation used to manufacture or 

assemble the printer head used on inkjet printers. Inkjet printing is a printing method 

where the liquid ink is transferred at high velocity through a small diameter opening(s) 

to a solid substrate.

2728. "Low Emission Spray Gun Cleaner": Any properly used spray gun equipment cleanup 

device which has passive solvent losses of no more than 0.6 grams per hour and has 

active solvent losses of no more than 15 grams per operating cycle as defined by the test 

method in Subsection E.6.

2829. "Low-Solids Adhesive, Sealant or Primer": Any product that containshas less than one 

pound of solids per gallon of material (120 grams or less of solids per liter of material). 

Such solids are the non-volatiles remaining after a sample is heated at 110oC for one 

hour.

2930. "Marine Deck Sealant": Any sealant intended by the manufacturer to be applied to 

wooden marine decks.

3031. "Marine Deck Sealant Primer": Any sealant primer intended by the manufacturer to be 

applied to wooden marine decks.

3132. "Multipurpose Architectural Adhesives": Any adhesive that is intended by the 

manufacturer to be used for the installation or repair of various construction materials or 

Formatted: Font: Times New (W1),

Superscript

Comment [SC8]: Consistent with new definition 

in Rule 74.13.
Proposed September 11, 2012 ATTACHMENT 4 Rule 74.20: 15

to bond architectural appurtenances, including but not limited to drywall, subfloor, 

panel, tileboard, deck and lumber, seams, fiberglass reinforced plastic (FRP), ceiling tile 

and acoustical tile. Adhesives used to bond uninstalled cabinets, counters, and other 

architectural appurtenances are subject to this adhesive category. 

3233. "Nonmembrane Roof Sealant/Adhesive": Any sealant or adhesive that is intended by 

the manufacturer to install or repair nonmembrane roofs and that is not intended for the 

installation of prefabricated single-ply flexible roofing membranes. This category 

includes plastic or asphalt roof cement, asphalt roof coatings, and cold application 

cement. 

3334. "Outdoor Carpet Adhesive": Any adhesive intended by the manufacturer for the 

installation of carpet or artificial turf that is not in an enclosure and is exposed to 

ambient weather conditions. 

3435. "Panel Adhesive": An adhesive that is intended by the manufacturer to be used for the 

installation of plywood. pre-decorated hardboard (or tileboard), fiberglass reinforced 

plastic, and similar pre-decorated or non-decorated panels to studs or solid surfaces.

3536. "Percent ROC by Weight": The ratio of the weight of ROC to the weight of the 

material, expressed as a percentage by weight. The percent ROC by weight is calculated 

as follows:

Wv

% ROC weight = X 100

W

Where Wv = Weight of the ROCs (grams)

W = Weight of the Material (grams)

3637. "Plastic Welding Primer": Any primer intended by the manufacturer to prepare plastic 

substrates prior to welding.

3738. "Plastic Foam": Any rigid or spongy cellular plastic mass with gas bubbles dispersed 

throughout. Examples include but are not limited to: urethane foams, PVC foams, 

Styrofoam, Foamboard and polyethylene foams.

3839. "Plastic Welding": The use of solvent-based adhesives to dissolve plastic surfaces to 

form a weld-like bond between mating surfaces. 

3940. "Plastic Welding Products": Any product intended by the manufacturer to weld plastic 

substrates, or to prepare plastic substrates prior to welding. These products include 

ABS welding products, cellulosic plastic welding products , CPVC welding products, 

PVC welding products, styrene-acrylonitrile welding products, plastic welding primers, 

and other plastic welding products.
Proposed September 11, 2012 ATTACHMENT 4 Rule 74.20: 16

4041. "Plastics": Synthetic materials chemically formed by the polymerization of organic 

(carbon-based) materials.

4142. "Polycarbonate": Polycarbonate is a type of thermoplastic "structural" foam and 

contains a plastic resin that can be found in Lexan manufactured by General Electric 

Company or in Tuffrak manufactured by Rohm and Haas Company.

4243. "Porous Material": A material whose surface is permeable to liquids; such materials 

include but are not limited to paper, and corrugated paperboard. 

4344. "PVC Welding Adhesive": Any adhesive intended by manufacturer to weld polyvinyl 

chloride (PVC) plastic. PVC plastic is a polymer of the chlorinated vinyl monomer that 

contains 57 percent chlorine and which is normally identified with a PVC marking.

4445. "Reactive Organic Compounds (ROC)": As defined in Rule 2, Definitions, of these 

Rules. The term "volatile organic compound" (VOC) is equivalent to ROC.

4546. "Roadway Sealant": Any sealant intended by the manufacturer to be applied to public 

streets, highways, and other surfaces, including but not limited to curbs, berms, 

driveways and parking lots.

4647. ROC Composite Partial Pressure": The sum of the partial pressures of the compounds 

defined as ROCs. ROC composite partial pressure is calculated as follows:

( )( )

( ) PP

W VP

MW

W

MW

W

MW

W

MW

c

i i

i i

n

w

w

e

e e

n i

i i

n = 



 



 + 



 



 + 



 





=

= =

∑

∑ ∑ 1

1 1

Where:

Wi = Weight of the "i"th ROC compound, in grams

Ww = Weight of water, in grams

We = Weight of the "e"th exempt organic compound, in grams

MWi = Molecular weight of the "i"th ROC compound, in g/(g-mole)

MWw = Molecular weight of water, in g/(g-mole)

MWe = Molecular weight of the "e"th exempt organic compound, in g/(g-mole)

PPc = ROC composite partial pressure at 20 C, in mm Hg 

VPi = Vapor pressure of the "i"th ROC compound at 20 C, in mm Hg.

4748. "Rubber": Rubber includes any natural or manmade rubber substrate, including but not 

limited to: styrene-butadiene rubber (SBR), polychloroprene (Neoprene), butyl rubber, 

nitrile rubber, chlorosulfonated polyethylene (CSM), and ethylene propylene diene 

terpolymer (EPDM).

4849. "Rubber Flooring Adhesive": Any adhesive intended by the manufacturer for the 

installation of flooring material in which both the back and the top surface are made of 

synthetic rubber, and which may be in sheet or tile form.
Proposed September 11, 2012 ATTACHMENT 4 Rule 74.20: 17

4950. "Sales Outlet": Any establishment at which adhesives, sealants, or primers can be sold 

in person to users of such products.

5051. "Sealant Primer": Any product intended by the manufacturer to be applied to a 

substrate, prior to the application of a sealant, to enhance the bonding surface.

5152. "Sealants": Any material with adhesive properties that is formulated primarily to fill, 

seal, waterproof or weatherproof gaps or joints between two surfaces. 

5253. "Sheet-Applied Rubber Lining Operations": The process of applying sheet rubber liners 

by hand to metal or plastic substrates in order to protect the underlying substrate from 

corrosion or abrasion. These operations also include laminating sheet rubber to fabric 

by hand.

5354. "Single-Ply Roof Membrane Adhesive Primer": Any primer intended by the 

manufacturer to clean and promote adhesion of the single-ply roof membrane seams or 

splices prior to bonding.

5455. "Single-Ply Roofing Membrane Installation/Repair Adhesive": An adhesive intended 

by the manufacturer to be used for the installation or repair of a prefabricated single-ply 

flexible roofing membrane. Single-ply roofing membranes are field-applied using just 

one layer of membrane material. The containers must be labeled exclusively for such 

use. Installation includes, as a minimum, attaching the edge of the membrane to the 

edge of the roof and applying flashing to the vents, pipes and ducts that protrude 

through the membrane. Repair includes gluing the edges of tears together, attaching a 

patch over a hole, and reapplying flashings to vents, pipes or ducts installed through the 

membrane.

5556. "Single-Ply Roofing Membrane Sealant": A sealant intended by the manufacturer to be 

used for the installation or repair of a prefabricated single-ply flexible roofing 

membrane. The containers must be labeled exclusively for such use.

5657. "Solvent": Organic, petrochemical compounds, which are used as diluents, thinners, 

dissolvers, reducers, cleaning agents, or for similar uses.

58. “Solvent Cleaning”: The use of solvent to remove loosely held uncured adhesives, 

uncured inks, uncured coatings, and contaminants, which include, but are not limited to, 

dirt, soil, and grease from parts, products, tools, machinery, equipment, and general 

work areas.

5759. "Special Purpose Contact Adhesive": Any contact adhesive that is used to bond 

melamine covered board, metal, unsupported vinyl, Teflon, ultra-high molecular weight 

polyethylene, rubber, or wood veneer 1/16 inch or less thick to any porous or nonporous 

surface.

Comment [SC9]: Consistent with definition in 

Rule 74.6
Proposed September 11, 2012 ATTACHMENT 4 Rule 74.20: 18

5860. "Structural Glazing Adhesive": Any adhesive that is intended by the manufacturer to be 

used to adhere glass, ceramic, metal, stone, or composite panels to exterior building 

frames. 

5961. "Structural Wood Member Adhesive": Any adhesive intended by the manufacturer to 

be used for the construction of a load-bearing joint in wooden joists, trusses, or beams.

6062. "Styrene-Acrylonitrile Welding ": Any adhesive intended by manufacturer to weld 

styrene-acrylonitrile co-polymer plastics. Bonding of styrene-acrylonitrile to any other 

substrate (such as metal) is not included under this plastic welding adhesive 

subcategory.

6163. "Subfloor Adhesive": Any adhesive intended by the manufacturer to be used for the 

installation of subflooring material over floor joists.

6264. Substrate Surface Preparation": Cleaning of a substrate to remove dirt, oils, and other 

contaminants. This surface cleaning is typically done prior to the application of 

primers, adhesives, or sealants.

6365. "Thermal Incineration": A direct-flame incinerator that depends on flame contact and 

high temperatures in the range of 1200 to 1500 oF to complete oxidation of ROCs. 

Thermal incinerators usually consist of refractory-lined chambers, burners, controllers, 

safety equipment and heat recovery equipment.

6466. "Thin Metal Laminating of Magnetic or Electronic Components": Any operation, 

excluding inkjet printer head assembly, that includes the bonding of multiple layers of 

metal to metal or metal to plastic in the production of electronic components or 

magnetic components, in which the bond line(s) is less than 0.25 mil.

6567. "Tire Repair": The repair of a hole, tear, fissure, or blemish in a tire casing by grinding 

or gouging, applying adhesive or sealant product and filling the hole or crevice with 

rubber.

6668. "Tire Retread": The process of tire retreading is where adhesives are applied to the back 

of precured tread rubber and to the casing and cushion rubber. It may also be used to 

seal buffed tire casings to prevent oxidation while the tire is being prepared for a new 

tread.

6769. "Top and Trim Adhesive": Any adhesive used to install automotive and marine trim, 

including, but not limited to headliners, vinyl tops, vinyl trim, sunroofs, dash covering, 

door covering, floor covering, panel covering, and upholstery.

6870. "Traffic Marking Tape": A preformed reflective film intended by the manufacturer to 

be applied to public streets, highways, and other surfaces, including but not limited to 

curbs, berms, driveways and parking lots.
Proposed September 11, 2012 ATTACHMENT 4 Rule 74.20: 19

6971. "Traffic Marking Tape Adhesive": Any adhesive intended by the manufacturer to be 

applied to surfaces prior to installation of traffic marking tape.

7072. "Undersea Based Weapons Systems Components": The fabricated part, assembly of 

parts or completed units of any portion of the missile launching system used on 

undersea ships.

7173. "VCT and Asphalt Tile Adhesive": Any adhesive intended by the manufacturer for the 

installation of Vinyl Composite Tile (VCT) or asphalt tile flooring. Vinyl composite 

tile is a material made from thermoplastic resins, fillers, and pigments.

7274. "Volatile Organic Compound (VOC)": Shall have the same meaning as Reactive 

Organic Compounds (ROC) as defined in Rule 2 of these Rules.

7375. "Wood Flooring Adhesive": Any adhesive intended by the manufacturer for the 

installation of wood flooring, which may include but is not limited to parquet tiles, 

wood planks, or strip-wood.